Republic of the Philippines

Regional Trial Court

6th Judicial Region
Iloilo City

OTHONIEL PADRONES SR.

Plaintiff, CIVIL CASE NO. ____
For: Collection of Sum of Money
-versus-

AARON JOSHUA TABALINA

Defendant.
x-----------------------------------------x

ANSWER
COMES NOW, the defendant by undersigned Counsel and in answer
to plaintiff’s complain in the above-entitled case, respectfully allege:

1. Defendant admit the averment in paragraph 1 of the complaint;

2. Defendant specifically deny the allegation in the paragraph 2 of the

complaint, the truth being that, Othoniel P. Padrones Sr. and the
defendant never seen and talked each other on December 24, 2017.

3. Defendant specifically deny the allegation in the paragraph 4 of the

complaint, the truth being that, the plaintiff never gave the defendants
the alleged amount of the One Million Pesos.

4. Defendant has no knowledge or information to form a belief as to the

truth of the due execution of the alleged promissory note.

5. Defendant specifically deny under oath in the paragraph 5 and 6 the

genuineness and due execution of the documents.

AFFIRMATIVE DEFENSES

Having answered the complaint, the Defendant, Aaron Joshua

Tabalina assert the following enumerated Affirmative Defenses.

1. All statements and comment made by Defendant about Plaintiff were

made by the Defendant with good motive and were fair comments.
 2. The plaintiff has failed to set forth ultimate facts due to inconsistency
of the statements as to the date of the alleged transaction executed
between the parties.

COUNTERCLAIM

Defendant, Aaron Joshua Tabalina allege;

1. That by virtue of this unwarranted and malicious act initiated by the

Plaintiff, Defendant was forced to engage counsel in the sum of Ten
Thousand Pesos (10,000.00)

WHEREFORE, it is respectfully prayed that the complaint be

dismissed and defendant be awarded the amount of Twenty Thousand
Pesos (20,000.00)

Other just and equitable reliefs are likewise prayed for.

Iloilo City, Iloilo – January 7, 2019

ATTY. HANNAH ABIGAIL J. LEGASPI

Iloilo City, Iloilo
Attorney’s Roll No.
IBP No.
PTR No.
MCLE Compliance No.

VERIFICATION CERTIFICATION

I, Aaron Joshua Tabalina, of legal age, Filipino Citizen, and residing at

Brgy. Pandac, Pavia, Iloilo, after first having duly sworn to in accordance
with the law depose and say:

1. I am the defendant in the above- entitled case.

2. I have caused the preparation of the foregoing complaint.
3. The contents therein are true and correct to the best of my personal
knowledge and based on authentic documents.
 4. I hereby certify that I have not commenced any action or proceeding
involving the same issue in any tribunal or agency, to the best of my
personal knowledge, no such action or proceeding is pending in any
other tribunal of agency and should I thereafter learn that a similar
action or proceeding has been filed or is pending in Court I will
undertake to report such fact within five (5) days threrefrom to the
Court wherein this Petition and this certification have been filed.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 7th

day of January in Iloilo City.

AARON JOSHUA TABALINA

Affiant

SUBSCRIBED AND SWORN to before me this 7th day of January in

Iloilo City, Philippines.

ATTY. HANNAH ABIGAIL J. LEGASPI

Iloilo City, Iloilo
Attorney’s Roll No.
IBP No.
PTR No.
MCLE Compliance No.
 CERTIFICATE OF SERVICE

I certify that on 7th of January, 2019, the original of this document was
filed with the clerk of Court, and, a true and accurate copy of this document
was served on the under party mail, addressed to the following:

TO: ATTY. ABIGAIL P. LOPEZ

Lopez Law Office, Jaro, Iloilo City

AARON JOSHUA TABALINA

Defendant

EXPLANATION

A copy hereof is served on opposing counsel and the Regional Trial

Court by registered mail, instead of by personal service, due to the urgency
of filing the same and due to lack of messenger of the undersigned counsel
for the moment.

ATTY. HANNAH ABIGAIL J. LEGASPI

Counsel for Defendant
 Republic of the Philippines
Regional Trial Court
6th Judicial Region
Iloilo City

PAUL JEANS SANCHES

Plaintiff, CIVIL CASE NO. ____
For: Collection of Sum of Money
-versus-

JASMINE DELOS REYES

Defendant.
x------------------------------------x

ANSWER
COMES NOW, the defendant by undersigned Counsel and in answer
to plaintiff’s complain in the above-entitled case, respectfully allege:

1. Defendant admit the averment in paragraph 1 of the complaint;

2. Defendant specifically deny the allegation in the paragraph 2 of

the complaint, the truth being that, Jasmine Delos Reyes and the
defendant never seen and talked each other on November 24,
2017.

3. Defendant specifically deny the allegation in the paragraph 4 of

the complaint, the truth being that, the plaintiff never gave the
defendants the alleged amount of the One Million Pesos.

4. Defendant has no knowledge or information to form a belief as to

the truth of the due execution of the alleged promissory note.

5. Defendant specifically deny under oath in the paragraph 5 and 6

the genuineness and due execution of the documents.

AFFIRMATIVE DEFENSES

Having answered the complaint, the Defendant, Jasmine Delos

Reyes assert the following enumerated Affirmative Defenses.
 1. All statements and comment made by Defendant about Plaintiff
were made by the Defendant with good motive and were fair
comments.

2. The plaintiff has failed to set forth ultimate facts due to

inconsistency of the statements as to the date of the alleged
transaction executed between the parties.

COUNTERCLAIM

Defendant, Jasmine Delos Reyes allege;

1. That by virtue of this unwarranted and malicious act initiated by the

Plaintiff, Defendant was forced to engage counsel in the sum of Ten
Thousand Pesos (10,000.00)

WHEREFORE, it is respectfully prayed that the complaint be

dismissed and defendant be awarded the amount of Twenty Thousand
Pesos (20,000.00)

Other just and equitable reliefs are likewise prayed for.

Iloilo City, Iloilo – January 7, 2019

ATTY. ABIGAIL P. LOPEZ

Iloilo City, Iloilo
Attorney’s Roll No.
IBP No.
PTR No.
MCLE Compliance No.

VERIFICATION CERTIFICATION

I, Jasmine Delos Reyes, of legal age, Filipino Citizen, and residing at Brgy.
Pandac, Pavia, Iloilo, after first having duly sworn to in accordance with the
law depose and say:

1. I am the defendant in the above- entitled case.

2. I have caused the preparation of the foregoing complaint.
 3. The contents therein are true and correct to the best of my personal
knowledge and based on authentic documents.

4. I hereby certify that I have not commenced any action or proceeding

involving the same issue in any tribunal or agency, to the best of my
personal knowledge, no such action or proceeding is pending in any
other tribunal of agency and should I thereafter learn that a similar
action or proceeding has been filed or is pending in Court I will
undertake to report such fact within five (5) days threrefrom to the
Court wherein this Petition and this certification have been filed.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 7th

day of January in Iloilo City.

JASMINE DELOS REYES

Affiant

SUBSCRIBED AND SWORN to before me this 7th day of January in

Iloilo City, Philippines.

ATTY. ABIGAIL P. LOPEZ

Iloilo City, Iloilo
Attorney’s Roll No.
IBP No.
PTR No.
MCLE Compliance No.
 CERTIFICATE OF SERVICE

I certify that on 7th of January, 2019, the original of this document was
filed with the clerk of Court, and, a true and accurate copy of this document
was served on the under party mail, addressed to the following:

TO: ATTY. HANNAH ABIGAI J. LEGASPI

Legaspi Law Office, Pavia Iloilo

JASMINE DELOS REYES

Defendant

EXPLANATION

A copy hereof is served on opposing counsel and the Regional Trial

Court by registered mail, instead of by personal service, due to the urgency
of filing the same and due to lack of messenger of the undersigned counsel
for the moment.

ATTY. ABIGAIL P. LOPEZ

Counsel for Defendant